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{{Adams | |||
| number = ML20207S788 | |||
| issue date = 03/06/1987 | |||
| title = Insp Rept 50-293/87-04 on 870112-16.Violations Noted: Inadequate Surveillance Test of Standby Gas Treatment Sys, Inadequate Test Program Procedures & Failure to Evaluate Effects of Out of Calibr Test Equipment | |||
| author name = Bissett P, Blumberg N, Evans M | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) | |||
| addressee name = | |||
| addressee affiliation = | |||
| docket = 05000293 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-293-87-04, 50-293-87-4, NUDOCS 8703200271 | |||
| package number = ML20207S763 | |||
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | |||
| page count = 18 | |||
}} | |||
See also: [[see also::IR 05000293/1987004]] | |||
=Text= | |||
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U.S. NUCLEAR REGULATORY COMMISSION | |||
, REGION I | |||
. | |||
Report No. 50-233/87-04 | |||
Jocket'No. 50-293 | |||
1 | |||
v' L'ic'et;.te No. DPR-35 | |||
\ | |||
Licenge: Boston Edison Company | |||
800 Boylston Street | |||
' | |||
Boston, Massachusetts 02199 | |||
^ | |||
FaciTfty Name: Pilgrim Nuclear Power Station | |||
.. 5' | |||
" | |||
Inspection At: Plymouth, Massachusetts | |||
> | |||
. | |||
, | |||
Inspection Conducted: January 12-16, 1987 | |||
5 | |||
Inspectors:, | |||
B" rg | |||
%1 7)b/S7 | |||
'N. Reactor E eer, DRS d te | |||
. | |||
d,Lha a/date | |||
sh7 | |||
) P.1 1ssett,-Reactor Engtheer, DRS | |||
, k.$AW | |||
M. Evans, Reactor Engineer, DRS da'te | |||
, | |||
L | |||
[ Approved by: -( $ 7 | |||
Dr. P. K. Eapen, Chief, Quality Assurance ' d4te | |||
Section, OPB, DRS | |||
Inspection Summary: Routine, Unannounced Inspection on January 12-16, 1987, | |||
Report No. 50-293/87-04. | |||
Areas Inspected: Routine unannounced inspection of licensee action on previous | |||
inspection findings, the surveillance testing program, instrument calibration, | |||
measurement and test equipment, new refueling bridge pre-operational testing | |||
and post modification surveillances, refueling bridge post modification | |||
training, surveillance testing for refueling operations and QA/QC interfaces. | |||
The insyction was performed on site by three region-based inspectors. | |||
Results: Fode violation were identified: (1) Inadequate surveillance test of | |||
3 the gSBGT system _ (para. 3.3.1); (2) Inadequate test program procedures (para | |||
, fi. 3.3f3, 5.3.2 and 6.3.2); (3) Failure to evaluate the effects of out of | |||
i , calkbration test equipment (para. 5.3.1); and (4) Failure to properly implement | |||
4 (s and maintain a test procedure (para. 6.3.2). | |||
Y | |||
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.t? , , DETAILS | |||
( ) 1.0.Pehso'nsContacted | |||
e $ Persons contacted are identified in Attachment A to this report. | |||
2.0 ' Licensee Action Concerning iPrevious Inspection Findings | |||
.1 | |||
y (Closed) Unresolved Item (50-293/84-28-05) - licensee to develop a | |||
Modification Management. Group , Work Instruction to establish the | |||
requirements for system walkdownsiby test directors prior to turnover from | |||
construction to preoperational testing. | |||
!! , | |||
". ' | |||
?,The inspector reviewed and discussed with the Modification Management | |||
Group Leader Section II of "the licensee's Modification Management Work | |||
Instruction Manual which describes'the requirements for system walkdowns | |||
prior to conducting any testing iof' the modified system. -The inspector | |||
noted that a checklist was provided -in the Work Instruction Manual to | |||
~ | |||
" | |||
document the findings, exceptions and ; system status identified during the | |||
?, | |||
' | |||
turnover process and prior to the commencement of preoperational testing. | |||
The inspector also reviewed severa,1 completed and approved checklists for | |||
j | |||
t | |||
four (4) modifications being conduc'ted during the'present plant outage and | |||
y verified proper documentation of the system turnover prior to start of | |||
f testing. This item is closed., | |||
' | |||
. | |||
3.0 SurveillanceTestingPrograrrj a | |||
' | |||
t '3.1 Scope and Criteria | |||
n' , , * | |||
N | |||
4 1' | |||
Y The licensee's surveillance test program was re' viewed for conformance | |||
y ,', to the following requirements: | |||
& 9 , | |||
-- | |||
10 CFR 50, Appendix'B c | |||
a c | |||
-- | |||
Pilgrim Station Technical Specifications (T.S.), Section 4, | |||
Surveillance Tests (Ph?S) n. | |||
, | |||
' | |||
-- | |||
Regulatory Guide 1.33, Quality Assurance Program (Operation) | |||
ANSI- N18.7-1976, Administrative Controls and Quality Assurance | |||
' | |||
-- | |||
for; the Operational Phase of Nuclerc, Power Plants. | |||
-- | |||
PNPS, Final Safety Analysis Report 'NSAR) | |||
-- | |||
Appropriate licenses administrative controls ~as listed in | |||
Attachment 8 to this report. | |||
' | |||
.. | |||
e Emphasis in this inspection was placed on programmatic aspects of the | |||
="t | |||
. , surveillance test program. Implementation was reviewed in the areas | |||
of instrument calibration (detailed in paragraph 4) and refueling | |||
' | |||
, , | |||
, | |||
4 | |||
? | |||
( | |||
, ' \ | |||
y | |||
. - . -- . .. - - | |||
_ _ _ .- | |||
. . | |||
3 | |||
surveillances (detailed in paragraph 5),. The inspection included | |||
review of technical specifications, test procedures, test schedules, | |||
and interviews with licensee personnel. | |||
3.2 Areas-Reviewed | |||
The licensee's surveillance test program, excluding the inservice | |||
testing of pumps and valves, was reviewed to ensure the following: | |||
-- | |||
Programs were established for the overall control of | |||
surveillance, instrument, post-maintenance, and post | |||
modification testing. | |||
-- | |||
A master test schedule for surveillance testing was established. | |||
-- | |||
Mechanisms were established for the tracking of completed tests. | |||
-- | |||
Completed tests received proper reviews. | |||
-- | |||
Test procedures were established for surveillance tests required | |||
by the T.S. | |||
-- | |||
Test procedures were established for each T.S. surveillance test | |||
requirement and accomplished T.S. objectives. | |||
-- | |||
Test schedules were being adhered to, and | |||
-- | |||
Surveillance test frequencies were as specified in the T.S. | |||
3.3 Findings | |||
3.3.1 The inspector used a sample of approximately 30 separate | |||
Technical Specification surveillance requirements to | |||
determine if the licensee had established procedures to | |||
implement these requirements. For each surveillance test | |||
which must be performed on a regularly scheduled basis the | |||
licensee was required to provide a test which met that | |||
surveillance requirement. | |||
In one instance, the test provided by the licensee appeared | |||
to be inadequate to meet the T.S. requirements. T.S. | |||
4.7.8.1.a.(4) requires that, at least once every 18 months, | |||
each branch of the standby gas treatment (SBGT) system be | |||
automatically initiated and the SBGT fans operated at 4000 | |||
CFM 10% during this initiation. The 18 month tests used | |||
by the licensee (8.M.2-1.5.8.3 and 1.5.8.4) perform | |||
automatic initiation only but do not operate the fans. The | |||
licensee stated this was done because other tests were . | |||
_ _ | |||
.. . | |||
. | |||
4 | |||
performed to check fan capacity. This T.S. specifically | |||
required an integrated operation, and the present test does | |||
not do this. Failure to adequately perform this T.S. | |||
surveillance is contrary to T.S. 4.7.B.1.a(4) and is | |||
considered a violation (50-293/87-04-01). | |||
In the above review, the inspector observed that some | |||
procedures were unclear as to their objectives. Incon- | |||
sistencies were noted and the following additional | |||
weaknesses were observed: | |||
-- | |||
T.S. sections were poorly referenced. In many cases | |||
the T.S. were not referenced at all or only the major | |||
paragraphs rather than subparagraphs were referenced. | |||
In addition, some referenced T.S. were incorrect or | |||
incomplete in that all T.S. requirements to be | |||
verified by the procedure were not referenced in the | |||
procedure. | |||
-- | |||
Procedure formats varied. There were major inconsis- | |||
tencies on how information was presented. | |||
-- | |||
Acceptance criteria were unclear. At times, | |||
acceptance criteria did not clearly state how the T.S. | |||
requirement was satisfied. Except as stated above | |||
there. were no instances identified where the. actual | |||
body of the test did not satisfy the T.S. requirement. | |||
The licensee recognized the need to improve surveillance | |||
test procedures. Consultants are currently rewriting | |||
procedures; however, no commitment was given by the | |||
licensee as to the expected completion date of this | |||
project. | |||
The T.S. contains contingency surveillance requirements. | |||
For example, SBGT filters must be sampled if they. are | |||
exposed to smoke, chemicals or paint fumes; the torus must | |||
be inspected if certain temperatures are reached. These | |||
requirements did not appear to be in appropriate procedures | |||
(such as a precaution in the SBGT operating procedure or | |||
SBGT filter sampling procedure). The inspector expressed a | |||
concern that these requirements could be overlooked if not | |||
placed in appropriate procedures. The licensee acknowl- | |||
edged the inspectors comments; however no commitment was | |||
made to include these T.S. in procedures. The licensee | |||
further stated, that in a recent instance when a | |||
contingency occurred it was not overlooked. | |||
, | |||
Recently a consultant (who was hired by the licensee to | |||
. .~. _ - -. . | |||
_ _ _ _ | |||
. - | |||
5 | |||
ensure that all T.S. surveillance tests were covered by a | |||
procedure) issued a report. This report was used by a | |||
licensee representative during this inspection to find | |||
procedures associated with each T.S. surveillance require- | |||
ment. The report pointed out problem areas to the if censee | |||
and made recommendations. As of the date of this | |||
inspection, the licensee had not taken action to address | |||
the concerns of this report nor to validate the procedure | |||
vs. T.S. cross reference. At the exit interview on January | |||
16, 1987, the licensee stated that action would be taken | |||
on this report in the near future. | |||
3.3.2 Previous NRC inspections and licensee event reports have | |||
identified occasions where scheduled surveillance tests | |||
were missed. The inspector reviewed the licensee's method | |||
for scheduling tests and Procedure 1.8, " Master | |||
Surveillance Tracking Program." In addition, the inspector | |||
4 held discussions with personnel who use, and input to, the | |||
master schedule; observed the mechanism by which tests are | |||
determined to have been completed. | |||
Procedure 1.8, Revision 4, dated August 1984, appeared to | |||
be lacking in its instructions to personnel. During this | |||
inspection a planned revision, Revision 5, to 1.8 was | |||
issued which was more comprehensive in its detail. | |||
Although basically acceptable, the inspector observed | |||
weaknesses in the program which could cause surveillance | |||
tests to be occasionally not performed. The mechanism for | |||
scheduling and tracking completed tests appeared to be | |||
cumbersome, inefficient and open to potential errors. | |||
The inspector made the following observations to the | |||
licensee: | |||
-- | |||
There is no centralized control of surveillance | |||
testing. Although there is a master schedule, each | |||
group controls its own surveillance tests. However, | |||
no group in the plant lias its own procedures for | |||
controlling its own test program. | |||
-- | |||
Although a computer controlled schedule is issued, its | |||
implementation is performed manually. Verification of | |||
completed tests is by initials on a copy of the | |||
computer schedule and depends on personnel from each | |||
section going to the Control Room Annex and initialing | |||
their completion. Initials are transposed as much as | |||
3 or 4 times. After the third transposition, entries | |||
are made to the computer. This system is prone to ! | |||
, transposition errors. l | |||
l | |||
. _ _ _ _ _ _ _ _ _ _ , , _ _ | |||
. . | |||
6 | |||
-- | |||
The planning and scheduling group is informed of | |||
changes to the schedule by the groups which perform | |||
the test. If a change is not entered in the computer | |||
it could be overlooked. There is no positive feedback | |||
to the group making the change that schedule changes | |||
have been actually made. | |||
-- | |||
Postponed tests or tests not applicable to the current | |||
mode are left on the weekly schedule for long periods | |||
of time. This leads to clutter on the schedule and | |||
potential errors with verification of completed tests. | |||
-- | |||
Each group maintains its own completed procedures. | |||
There is no routine independent review (outside tne | |||
implementing group and other than sampling by QA) that | |||
tests have actually been completed. Test planners do | |||
not see completed tests but only initials on a | |||
schedule. | |||
The licensee acknowledged the inspectors comments and | |||
stated that they recognized problems with the current | |||
method of scheduling. They also indicated that action was | |||
being taken to improve the current methods of scheduling | |||
and controlling surveillance tests. | |||
3.3.3 Except for the Master Surveillance Test Schedule procedure, | |||
there appeared to be no administrative procedures for | |||
control of test programs. While licensee representatives | |||
were able to discuss mechanisms by which they control their | |||
surveillance test programs no administrative procedures | |||
were in place. In accordance with Station Procedure 1.8, | |||
each station group has the responsibility for performing | |||
their own surveillances. The lack of test programs was | |||
also observed in the areas of I&C calibration and post- | |||
modification testing. | |||
ANSI Standard 18.7-1976, Paragraph 5.2.19, requires the | |||
establishment of program procedures for the conduct and | |||
control of surveillance test programs, post-maintenance | |||
testing, and post modification testing. In addition, the | |||
BECO QAM, Section 11, requires that all tests be performed | |||
by qualified personnel; that approved test procedures be | |||
established; that test procedures identify all prerequi- | |||
sites and environmental conditions; that the Watch Engineer | |||
or his designee evaluate and approve post modification and | |||
post maintenance test results; and that the N0D Manager is | |||
responsible for the evaluation and approval of periodic | |||
surveillance test results. Although there is an adminis- | |||
trative control procedure for the scheduling of periodic | |||
. . | |||
. | |||
7 | |||
surveillance tests and for the preparation of periodic | |||
surveillance tests, other programmatic aspects were not | |||
included in procedures. Some examples of items should have | |||
been included but were not included: | |||
-- | |||
Mechanisms for overall control and performance of | |||
tests. | |||
-- | |||
Definition of personnel qualified to perform tests. | |||
-- | |||
Methods by which prerequisites and environmental | |||
conditions are to be determined. | |||
-- | |||
Specifications of personnel who are designated to | |||
approve and evaluate test results. | |||
-- | |||
Definitions of the kinds of instruments to be included | |||
in the instrument and control surveillance test | |||
program. | |||
-- | |||
Methods by which acceptance criteria are properly | |||
specified. | |||
-- | |||
Journal for post maintenance and post modification | |||
test procedures. | |||
Failure to establish an overall test program Administrative | |||
Control procedure is contrary to 10 CFR 50, Appendix B, | |||
Criterion XI; ANSI N18.7-1976, paragraph 5.2.19; and BECO | |||
QAM Section 11 and is considered a violation (50-293/ | |||
87-04-04). | |||
4. Instrument Calibration | |||
4.1 Scope and Criteria | |||
Refer to paragraph 3.1. | |||
4.2 Program Review / Implementation | |||
The inspector held discussions with Maintenance Group personnel to | |||
evaluate those controls in place used to identify, schedule, track, | |||
perform, and document calibration activities required by Technical | |||
Specifications (T.S.). Also reviewed were those controls in place | |||
that are used during the calibration of selected instrumentation that | |||
support the performance of T.S. related surveillances. | |||
The majority of instrument calibrations are performed by the Instru- | |||
ment and Controls (I&C) section. The overall performance of the site | |||
- - , . _ - . .. - _ . | |||
. _. . . .- -. .. | |||
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ | |||
. . | |||
8 | |||
calibration program is controlled via the Master Surveillance Track- | |||
ing Program, thus calibration activities are designated as station | |||
surveillance requirements. Scheduling of calibration activities is | |||
controlled and documented through either weekly, monthly or semi- | |||
annual surveillance test schedules. Each station group and their | |||
respective sub groups are responsible for the performance of | |||
scheduled calibrations. This includes the development and updating | |||
of the data base, the performance, documentation and subsequent | |||
revisions of completed calibrations. | |||
Further discussions with Compliance and Administrative Group, Project | |||
Control Group, and Maintenance sub group personnel included a review | |||
of the following: | |||
* | |||
Weekly and monthly surveillance test schedules | |||
* | |||
Semi-annual Master Surveillance Tracking Program Test List | |||
Variance Reports / Priority Notice Reports, and | |||
Various surveillance procedures used during the performance of | |||
calibrations | |||
The inspector verified that calibration methods and associated | |||
l frequencies had been established for installed instrumentation used | |||
, during the performance of Technical Specification required | |||
surveillances. As with Technical Specification required calibra- | |||
! tions, these installed instrument calibrations are tracked, scheduled | |||
and performed under the Master Surveillance Tracking Program. The | |||
inspector selected four surveillance requirements associated with the | |||
; | |||
' | |||
1) Standby Liquid Control Syst.em; 2) Standby Gas Treatment System and | |||
the 3) Fire Protection System. This selection was made in order to | |||
provide assurance that 1) installed instrumentation required to | |||
support the completion of T.S. surveillances were included in the | |||
Master Surveillance Test Schedule, 2) required frequencies had been | |||
established, and 3) calibrations were being performed. From the | |||
above selected surveillance requirements, the licensee was requested | |||
to provide the appropriate surveillance procedure number which | |||
documented the calibration of associated instrumentation used during | |||
the performance of these surveillances. Subsequently, the inspector | |||
reviewed the appropriate surveillance procedures which documented the | |||
performance of these calibrations. | |||
The inspector also observed a performance of surveillance procedure | |||
8.M.2.-l.1 " Primary Containment Isolation System - Reactor High | |||
Pressure" calibration and 8.M.2-2.10.2-16, " Low Pressure Coolant | |||
Injection Break Detection Logic Functional Test - Division A". NRC | |||
observation of these surveillances was conducted to verify that the | |||
following was accomplished. | |||
. | |||
. | |||
. | |||
- | |||
. . | |||
9 | |||
Applicable surveillance procedures were approved, up-to-date, | |||
and used throughout the conduct of the surveillance. | |||
* | |||
Appropriate personnel were notified prior to the start of the | |||
test. | |||
* | |||
Calibrated test equipment was used. | |||
Acceptance criteria were met, and if not, appropriate corrective | |||
action was taken. | |||
* | |||
Properly specified parts and materials were identified, and | |||
Following completion of the test, systems were aligned for | |||
normal operation. | |||
During the calibration of Reactor High Pressure sensor PS-261-23A, | |||
"As-Found" values were found to be out-of-tolerance. The Barksdale | |||
Switch adjustment cover and eventually the switch cover itself, had | |||
to be removed in order for the I&C technicians to make the necessary | |||
adjustment to bring the pressure sensor within the allowable | |||
operating range. Subsequent inspection of the environmentally | |||
qualified Barksdale switch cover plate gasket indicated the need for | |||
replacement. However, the I&C technicians were unable to obtain a | |||
new gasket because none were found in stock at the site. To provide | |||
assurance that the gasket is replaced a work order was generated | |||
against the pressure switch and the surveillance is not be considered | |||
complete until the new gasket is replaced. | |||
4.3 Findings | |||
The inspector expressed some concern over the lack of programmatic | |||
controls for controlling calibration activities. This also applies | |||
to the calibration of installed instrumentation used to support | |||
Technical Specification surveillances. Only through discussions with | |||
various site personnel, was the inspector able to ascertain how the | |||
calibration program was controlled and conducted. This is an example | |||
of lack of programmatic controls contributing to the violation | |||
identified in paragraph 3.3.3. above. | |||
5. Measurement and Test Equipment (M&TE) | |||
5.1 Scope and Criteria | |||
Refer to paragraphs 3.1. | |||
5.2 Program Review / Implementation | |||
The inspector held discussions with individuals designated to ad- | |||
. . | |||
10 | |||
minister and control the site's measuring and test equipment. Con- | |||
trol of this program is designated in Procedure 1.3.36, " Measurement | |||
and Test Equipment". A review of this procedure governing the con- | |||
trol of M&TE was conducted and verified to ensure that the program | |||
was being implemented as intended. This verification included a | |||
review of the following. | |||
* | |||
Calibration records | |||
* | |||
Toolroom controls | |||
* | |||
Equipment master list for I&C and Station Services | |||
* | |||
M&TE records | |||
* | |||
Staffing | |||
A tour of the tool rooms controlled by the I&C group and the Station | |||
Services Group and discussions with tool room attendants and their | |||
supervisors was conducted to verify that the storage and issuance of | |||
M&TE were being adequately controlled. | |||
5.3 Findings | |||
5.3.1 Issuance and retrieval of all M&TE is handled by the | |||
toolroom attendants. M&TE was adequately controlled | |||
through the utilization of calibration logs, history | |||
records and issuance logs. Equipment was found to be | |||
appropriately stored and identified. M&TE was found to | |||
fall into one of the following categories: | |||
* | |||
Out for re-calibration | |||
* | |||
Segregated (due for re-calibration or inoperable) | |||
* | |||
In-use, and | |||
* | |||
j Restricted use | |||
5.3.2 During the inspectors review of past calibration records, | |||
it was determined that historical use evaluations for M&TE | |||
found to be out-of-calibration was not being performed as | |||
required by ANSI 18.7, and the PNPS M&TE Procedure 1.3.36. | |||
Over 18 instances were found where these evaluations were | |||
not completed by I&C and Station Services. Much of the | |||
i problem with the Station Services group is attributable to | |||
their not following through with the evaluation by not | |||
contacting various groups to which were 'ssued evaluations | |||
for corrective action. This lack of followup and interface | |||
-. -- . -- - | |||
- - - . - - = _. . _ _ _ . . - . . - . - | |||
. . | |||
11 | |||
resulted in the failure of the other groups to complete the | |||
necessary actions. I&C attributed their failure to com- | |||
plete these evaluations to staffing problems. | |||
Failure to evaluate and document the effect of out-of- | |||
calibration test equipment on previously performed tests is | |||
contrary to ANSI N 18.7-1976, paragraph 5.2.16 and is | |||
considered a violation (50-293/87-04-02). | |||
No other violations or deficiencies were observed. | |||
6.0 Refuel Bridge Modification and Preoperational Testing | |||
6.1 Background and Purpose of the Inspection | |||
The refueling bridge at Pilgrim Station is a rolling hoist primarily | |||
to load new fuel into the reactor and remove the old fuel during | |||
refueling outages. | |||
The previous refueling bridge had a long history of both mechanical | |||
and electrical equipment failure. The bridge failures during | |||
previous refueling operations had caused considerable lost outage | |||
time while repairs were being made. In addition, the frame of the | |||
refueling bridge had been deformed and the controls were outdated. | |||
Because of these problems, the licensee decided to replace the | |||
existing refueling bridge with a new BWR 6 refueling bridge. Some | |||
features of this new bridge include upgraded controls and drive | |||
mechanism, improved high capacity air supply and semiautomatic | |||
control. . | |||
The purpose of this inspection was to verify that adequate preopera- | |||
, tional testing of the new refueling bridge would be conducted prior | |||
to the operational use of the bridge. In addition, the inspector | |||
reviewed the areas of post mcdification training and surveillance | |||
testing to determine that the licensee had adequately addressed these | |||
areas in regard to the refueling bridge modification. | |||
6.2 Criteria and Documents Reviewed | |||
See paragraph 3.2 and Attachments B and C. | |||
6.3 Scope | |||
The inspector reviewed preoperational test procedures TP86-127 and | |||
TP86-182 for the refueling bridge. These procedures were reviewed in | |||
preparation for test witnessing, for technical and administrative | |||
adequacy and to independently verify that testing satisfied | |||
regulatory guidance and licensee commitments. They were also | |||
reviewed to verify licensee review and approval, proper format, test | |||
. . | |||
12 | |||
objectives, prerequisites, initial conditions, test data recording | |||
requirements and system return to normal. In addition, completed | |||
portions of TP86-127 were reviewed. No refueling bridge testing was | |||
conducted during this inspection. | |||
6.4 Findings | |||
During the above review, the inspector verified that the refueling | |||
bridge interlocks described in the vendor's Instruction Manual | |||
IM-01620, appeared to be adequately tested in the preoperational test | |||
procedures. However, during the review of TP86-127, Section 11, | |||
" Traveling Safety Control Interlock", the inspector noted discrepan- | |||
cies in the refueling bridge positions for testing conducted in Zone | |||
II (canal joining spent fuel pool to reactor cavity area) and Zone | |||
III (spent fuel pool). These interlocks are provided to eliminate | |||
the possibility of the fuel grapple running into the wall. | |||
Specifically, after review of TP86-127, Attachment D, figure 1, which | |||
shows the 3 zones in which the main hoist can travel, it appeared to | |||
the inspector that bridge position numbers identified in Section II, | |||
Zone II.b and Zone III.c. were incorrect. | |||
The inspector discussed this concern with the licensee test director | |||
who had performed this portion of the procedure on October 8,1986. | |||
The test director stated that the refueling bridge position numbers | |||
listed in the procedure were incorrect and that at the time he | |||
conducted the test he had intended to correct the procedure. | |||
Instead, he performed this section of the test using the correct | |||
bridge position numbers and signed off the steps in the procedure as | |||
complete, but failed to change the bridge position numbers in the | |||
procedure and ensure that this was properly approved. This | |||
constitutes a violation of Technical Specification 6.8.A for failure | |||
to properly implement and maintain the procedure (50-293/87-04-03). | |||
In addition to the concerns addressed above, the inspector discussed | |||
the control of the conduct of the preoperational tests following | |||
modifications with various licensee representatives. The inspector | |||
found that no specific programmatic procedure which list the require- | |||
ments for such items as testing holds and failure to meet acceptance | |||
criteria during conduct of the test existed. The absence of a | |||
procedure to control the conduct of preoperational testing is another | |||
example of the violation discussed in paragraph 3.3.3 above. | |||
7.0 Refueling Bridge Post Modification Training | |||
The inspector discussed the training of licensee personnel concerning the | |||
refueling bridge modification with two licensee training representatives. | |||
They explained that training includes the following: | |||
. | |||
- . , - - . , , - - - . . - - - | |||
-----w- - - - - ,e. . . - - | |||
- | |||
-, | |||
.. | |||
. .o | |||
-. | |||
13 | |||
-- | |||
An on watch discussion with each licensed and unlicensed operator on | |||
the applicability and requirements of the documents listed in | |||
Attachment D, and | |||
-- | |||
Hands-on training in the operation of the new refueling bridge for | |||
all licensed and unlicensed operators. | |||
The licensee representatives explained that the on-watch discussions have | |||
already been conducted and the hands-on training will occur after the | |||
refueling bridge preoperational testing has been completed and the system | |||
turned over to operations. In addition, they noted that after the review | |||
of the procedures listed in Attachment D, all changes to the procedures as | |||
a result of the refueling bridge modification have been discussed with the | |||
operators. | |||
No deficiencies were identified with regard to the' licensee's program for | |||
refueling bridge post modification training. | |||
8.0 Surveillance Testing for Refueling Operations | |||
8.1 Scope and Criteria | |||
The inspector reviewed Procedure 4.3, " Fuel Handling", in order to | |||
verify that the licensee had identified the surveillance testing | |||
needed to be conducted prior to and during fuel loading / unloading. | |||
The inspector noted that Procedure 4.3 included attachments which | |||
identified the requirements for either specific systems to be | |||
operable or specific surveillance test procedures to be performed. | |||
The inspector compared these attachments with the Technical Speci- | |||
fication requirements for fuel loading / unloading. See Paragraph 3.1 | |||
and Attachment B for requirements and inspection criteria. | |||
8.2 Findings | |||
The inspector noted that the Control Room high efficiency air | |||
filtration system required to be operable per T.S. 3.7.B.2 was not | |||
addressed in Procedure 4.3. The inspector questioned a licensee | |||
representative concerning this item. He stated that this item had | |||
been previously identified and was to be included in the next | |||
revision of the procedure. The inspector reviewed a draft copy of | |||
the procedure revision and verified that the requirement for system | |||
operability was included. In addition, during review of Procedure | |||
4.3, the inspector noted that step 18, of Attachment OPER-10 | |||
identified surveillance testing to be conducted per T.S. Table 3.1.1. | |||
note 7. Step 18 specifically references three surveillance tests to | |||
be conducted. However, the surveillances for reactor mode switch in | |||
shutdown, manual scram and scram discharge volume high level are not | |||
referenced in this step. After discussion with the licensee | |||
representative, he committed to including a reference to these | |||
, | |||
_ - . . _ , , , - , - - - - - . _ - _ _ . - - - , - - . _ _ _ _ . - . - | |||
- _ . - | |||
- - - _ - - - - , . . . - - - . . . - , | |||
-. | |||
. . | |||
14 | |||
surveillances in step 18 of OPER-10. No violations or other | |||
deficiencies were identified. | |||
9.0 Quality Assurance / Quality Control (QA/QC) Interface | |||
The Quality Assurance group is represented on-site, along with Quality | |||
Control personnel. Thus, these independent groups are able to actively | |||
monitor on going station activities. Discussions were held with the | |||
Senior QA Engineer to ascertain QA's involvement with the site's | |||
calibration and surveillance program. It was noted that a QA surveillance | |||
program is in place to provide QA coverage of various site activities, | |||
including the performance of calibrations and surveillances. A review of | |||
completed QA surveillances within the area of calibration and surveil- | |||
lances, performed during the past 12 months indicates that QA's | |||
participation is adequate, for present staffing levels. | |||
Approximately 17 QA surveillance reports were reviewed by the inspectors. | |||
This review included the following: | |||
* | |||
Surveillance checklists | |||
Evaluation sheets | |||
* | |||
Nonconformance reports, if applicable | |||
Trending input sheets, and | |||
Department responses, if applicable. | |||
It was noted that QA personnel were identifying problems in areas such as | |||
procedure adherence, inadequate procedure content, and usage of out-of- | |||
calibration equipment. Station response and subsequent corrective action | |||
to the items reviewed appeared to be timely as noted during the | |||
inspector's review of the QA's weekly deficiency status report. | |||
10.0 Management Meetings | |||
Licensee management was informed of the scope and purpose of the | |||
inspection at an entrance interview conducted on January 12, 1987. The | |||
findings of the inspection were periodically discussed with licensee | |||
representatives during the course of the inspection. An exit interview | |||
was conducted on January 16,1987 (see Attachment A attendees) at which | |||
time the findings of the inspection were presented. | |||
At no time during this inspection was written material concerning | |||
inspection findings provided to the licensee by the inspectors. | |||
A subsequent telephone discussion concerning clarification of the | |||
inspection findings was conducted between the inspector and Mr. E. Graham | |||
on January 21, 1987. | |||
. . | |||
i | |||
ATTACHMENT A | |||
PERSONS CONTACTED | |||
1. Licensee | |||
*M. Akhtar Group Leader - Modifications Management | |||
*M. Brosee Maintenance Section Manager | |||
F. Famulari Quality Control (QC) Group Leader | |||
D. Gerlits Senior Nuclear Training Specialist | |||
F. Giardiello Compliance Engineer | |||
*E. Graham Compliance Group Leader | |||
*R. Grazio Field Engineering Section Manager | |||
P. Hamilton Compliance Engineer | |||
*S. Hudson Operations Section Manager | |||
G. LaFond I&C Engineer | |||
E. Larson Senior QA Engineer | |||
*P. Mastrangelo Chief Operations Engineer | |||
*L. Mcdonald Nuclear Management Service Department | |||
Group Leader | |||
M. McGuire Electrical Engineer | |||
P. Moraites Assistant Chief Maintenance Engineer | |||
S. Musial Tool Management Supervisor | |||
A. Pederson Station Manager | |||
K. Roberts Director of Outage Management | |||
C. Santora Planning Analyst | |||
R. Schifone Compliance Engineer | |||
J. Serry | |||
R. Sherry Chief Maintenance Engineer | |||
D. Sukanek Station Services Group Leader | |||
J. Thompson Training Requalification Instructor | |||
J. Vender Mechanical Engineer | |||
D. Witecki I&C Senior Engineer (Quadrex) | |||
S. Wollman Principal Operations Engineer | |||
*E. Ziemanski Nuclear Management Services Section Manager | |||
The inspector also interviewed other licensee personnel including I&C | |||
Technicians. | |||
2. USNRC | |||
M. McBride Senior Resident Inspector | |||
*J. Lyash Resident Inspector | |||
* Denotes those present at exit interview. | |||
d' | |||
' | |||
t+ | |||
ATTACHMENT B | |||
' PROCEDURES REVIEWED FOR CONTROL OF | |||
SURVEILLANCE TESTING AND CALIBRATION | |||
-- | |||
1.3.4 Procedures | |||
-- | |||
1.3.6 Adherence to Technical Specifications | |||
-- 1.3.36 Measurement and Test Equipment | |||
~ - - | |||
1.8 Master Surveillance Tracking Program | |||
-- | |||
'1.8.2 PM Tracking Program | |||
-- | |||
2.1.5 Daily Surveillance Log (Technical Specifications and Regulatory | |||
Agencies) | |||
-- | |||
4.3 Fuel Handling | |||
= | |||
a | |||
. | |||
L | |||
ATTACHMENT C | |||
REFERENCES REVIEWED FOR CONTROL OF | |||
MODIFICATION AND TESTING OF THE | |||
REFUELING BRIDGE | |||
-- | |||
Pilgrim Nuclear dawer Station (PNPS), Technical Specifications | |||
-- | |||
PNPS, Final Safety Analysis Report (FSAR) | |||
-- | |||
Nuclear Operatio1s Procedure 83A6 (N0P83A6), Modification Management, | |||
July 31, 1984. | |||
-- | |||
Nuclear Operations Procedure 83E1 (N0P93EI), Control of Modifications to | |||
Pilgrim Station, September 17, 1986. | |||
-- | |||
Nuclear Operations Department, PNPS, Procedure No. TP86-127, Preoperation- | |||
al Test for Refueling Bridge, Revision 6, January 7, 1987. | |||
-- | |||
Nuclear Operations Department, PNPS, Procedure No. TP86-182, Preoperation- | |||
al Test for Refueling Bridge / Vessel Disassembled, Revision 0, January 3, | |||
1987. | |||
-- | |||
Instruction Manual IM-01620, Refueling Platform BECO, Pilgrim Station, | |||
P.O. No. 68521, Volume 1 of 2, Revision 0, February 25, 1986. | |||
-- | |||
Safety Evaluation, PNPS, No. 2044, Approved January 6, 1987. | |||
-- | |||
Modification Management Work Instruction Manual, Approved January 12, | |||
1987. | |||
1 | |||
:. - | |||
ATTACHMENT D | |||
PROCEDURES AND DOCUMENTS INCLUDED | |||
IN REFUELING BRIDGE POST MODIFICATION TRAINING | |||
--- | |||
Technical Specifications 3.10 " Core Alterations", and bases. | |||
-- | |||
Technical Specifications 3.3 " Reactivity Control", and bases. | |||
-- | |||
PNPS Procedure 4.0 "SNM Inventory and Transfer Control". | |||
-- | |||
PNPS Procedure 4.3 " Fuel Handling". | |||
-- | |||
PNPS Procedure 5.4.2 " Refueling Floor High Radiation". | |||
-- | |||
PNPS Procedure 2.2.75 " Fuel Handling and Servicing | |||
Equipment". | |||
-- | |||
PNPS Procedure 4.5 " Reactor Core Fuel Verification". | |||
-- | |||
PNPS Procedure 8.10.1 " Refueling Interlocks Functional | |||
through 8.10.6 Tests". | |||
}} |
Latest revision as of 13:53, 19 December 2021
ML20207S788 | |
Person / Time | |
---|---|
Site: | Pilgrim |
Issue date: | 03/06/1987 |
From: | Bissett P, Blumberg N, Marilyn Evans NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
To: | |
Shared Package | |
ML20207S763 | List: |
References | |
50-293-87-04, 50-293-87-4, NUDOCS 8703200271 | |
Download: ML20207S788 (18) | |
See also: IR 05000293/1987004
Text
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U.S. NUCLEAR REGULATORY COMMISSION
, REGION I
.
Report No. 50-233/87-04
Jocket'No. 50-293
1
v' L'ic'et;.te No. DPR-35
\
Licenge: Boston Edison Company
800 Boylston Street
'
Boston, Massachusetts 02199
^
FaciTfty Name: Pilgrim Nuclear Power Station
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Inspection At: Plymouth, Massachusetts
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.
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Inspection Conducted: January 12-16, 1987
5
Inspectors:,
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'N. Reactor E eer, DRS d te
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) P.1 1ssett,-Reactor Engtheer, DRS
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M. Evans, Reactor Engineer, DRS da'te
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[ Approved by: -( $ 7
Dr. P. K. Eapen, Chief, Quality Assurance ' d4te
Section, OPB, DRS
Inspection Summary: Routine, Unannounced Inspection on January 12-16, 1987,
Report No. 50-293/87-04.
Areas Inspected: Routine unannounced inspection of licensee action on previous
inspection findings, the surveillance testing program, instrument calibration,
measurement and test equipment, new refueling bridge pre-operational testing
and post modification surveillances, refueling bridge post modification
training, surveillance testing for refueling operations and QA/QC interfaces.
The insyction was performed on site by three region-based inspectors.
Results: Fode violation were identified: (1) Inadequate surveillance test of
3 the gSBGT system _ (para. 3.3.1); (2) Inadequate test program procedures (para
, fi. 3.3f3, 5.3.2 and 6.3.2); (3) Failure to evaluate the effects of out of
i , calkbration test equipment (para. 5.3.1); and (4) Failure to properly implement
4 (s and maintain a test procedure (para. 6.3.2).
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.t? , , DETAILS
( ) 1.0.Pehso'nsContacted
e $ Persons contacted are identified in Attachment A to this report.
2.0 ' Licensee Action Concerning iPrevious Inspection Findings
.1
y (Closed) Unresolved Item (50-293/84-28-05) - licensee to develop a
Modification Management. Group , Work Instruction to establish the
requirements for system walkdownsiby test directors prior to turnover from
construction to preoperational testing.
!! ,
". '
?,The inspector reviewed and discussed with the Modification Management
Group Leader Section II of "the licensee's Modification Management Work
Instruction Manual which describes'the requirements for system walkdowns
prior to conducting any testing iof' the modified system. -The inspector
noted that a checklist was provided -in the Work Instruction Manual to
~
"
document the findings, exceptions and ; system status identified during the
?,
'
turnover process and prior to the commencement of preoperational testing.
The inspector also reviewed severa,1 completed and approved checklists for
j
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four (4) modifications being conduc'ted during the'present plant outage and
y verified proper documentation of the system turnover prior to start of
f testing. This item is closed.,
'
.
3.0 SurveillanceTestingPrograrrj a
'
t '3.1 Scope and Criteria
n' , , *
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4 1'
Y The licensee's surveillance test program was re' viewed for conformance
y ,', to the following requirements:
& 9 ,
--
10 CFR 50, Appendix'B c
a c
--
Pilgrim Station Technical Specifications (T.S.), Section 4,
Surveillance Tests (Ph?S) n.
,
'
--
Regulatory Guide 1.33, Quality Assurance Program (Operation)
ANSI- N18.7-1976, Administrative Controls and Quality Assurance
'
--
for; the Operational Phase of Nuclerc, Power Plants.
--
PNPS, Final Safety Analysis Report 'NSAR)
--
Appropriate licenses administrative controls ~as listed in
Attachment 8 to this report.
'
..
e Emphasis in this inspection was placed on programmatic aspects of the
="t
. , surveillance test program. Implementation was reviewed in the areas
of instrument calibration (detailed in paragraph 4) and refueling
'
, ,
,
4
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(
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. - . -- . .. - -
_ _ _ .-
. .
3
surveillances (detailed in paragraph 5),. The inspection included
review of technical specifications, test procedures, test schedules,
and interviews with licensee personnel.
3.2 Areas-Reviewed
The licensee's surveillance test program, excluding the inservice
testing of pumps and valves, was reviewed to ensure the following:
--
Programs were established for the overall control of
surveillance, instrument, post-maintenance, and post
modification testing.
--
A master test schedule for surveillance testing was established.
--
Mechanisms were established for the tracking of completed tests.
--
Completed tests received proper reviews.
--
Test procedures were established for surveillance tests required
by the T.S.
--
Test procedures were established for each T.S. surveillance test
requirement and accomplished T.S. objectives.
--
Test schedules were being adhered to, and
--
Surveillance test frequencies were as specified in the T.S.
3.3 Findings
3.3.1 The inspector used a sample of approximately 30 separate
Technical Specification surveillance requirements to
determine if the licensee had established procedures to
implement these requirements. For each surveillance test
which must be performed on a regularly scheduled basis the
licensee was required to provide a test which met that
surveillance requirement.
In one instance, the test provided by the licensee appeared
to be inadequate to meet the T.S. requirements. T.S.
4.7.8.1.a.(4) requires that, at least once every 18 months,
each branch of the standby gas treatment (SBGT) system be
automatically initiated and the SBGT fans operated at 4000
CFM 10% during this initiation. The 18 month tests used
by the licensee (8.M.2-1.5.8.3 and 1.5.8.4) perform
automatic initiation only but do not operate the fans. The
licensee stated this was done because other tests were .
_ _
.. .
.
4
performed to check fan capacity. This T.S. specifically
required an integrated operation, and the present test does
not do this. Failure to adequately perform this T.S.
surveillance is contrary to T.S. 4.7.B.1.a(4) and is
considered a violation (50-293/87-04-01).
In the above review, the inspector observed that some
procedures were unclear as to their objectives. Incon-
sistencies were noted and the following additional
weaknesses were observed:
--
T.S. sections were poorly referenced. In many cases
the T.S. were not referenced at all or only the major
paragraphs rather than subparagraphs were referenced.
In addition, some referenced T.S. were incorrect or
incomplete in that all T.S. requirements to be
verified by the procedure were not referenced in the
procedure.
--
Procedure formats varied. There were major inconsis-
tencies on how information was presented.
--
Acceptance criteria were unclear. At times,
acceptance criteria did not clearly state how the T.S.
requirement was satisfied. Except as stated above
there. were no instances identified where the. actual
body of the test did not satisfy the T.S. requirement.
The licensee recognized the need to improve surveillance
test procedures. Consultants are currently rewriting
procedures; however, no commitment was given by the
licensee as to the expected completion date of this
project.
The T.S. contains contingency surveillance requirements.
For example, SBGT filters must be sampled if they. are
exposed to smoke, chemicals or paint fumes; the torus must
be inspected if certain temperatures are reached. These
requirements did not appear to be in appropriate procedures
(such as a precaution in the SBGT operating procedure or
SBGT filter sampling procedure). The inspector expressed a
concern that these requirements could be overlooked if not
placed in appropriate procedures. The licensee acknowl-
edged the inspectors comments; however no commitment was
made to include these T.S. in procedures. The licensee
further stated, that in a recent instance when a
contingency occurred it was not overlooked.
,
Recently a consultant (who was hired by the licensee to
. .~. _ - -. .
_ _ _ _
. -
5
ensure that all T.S. surveillance tests were covered by a
procedure) issued a report. This report was used by a
licensee representative during this inspection to find
procedures associated with each T.S. surveillance require-
ment. The report pointed out problem areas to the if censee
and made recommendations. As of the date of this
inspection, the licensee had not taken action to address
the concerns of this report nor to validate the procedure
vs. T.S. cross reference. At the exit interview on January
16, 1987, the licensee stated that action would be taken
on this report in the near future.
3.3.2 Previous NRC inspections and licensee event reports have
identified occasions where scheduled surveillance tests
were missed. The inspector reviewed the licensee's method
for scheduling tests and Procedure 1.8, " Master
Surveillance Tracking Program." In addition, the inspector
4 held discussions with personnel who use, and input to, the
master schedule; observed the mechanism by which tests are
determined to have been completed.
Procedure 1.8, Revision 4, dated August 1984, appeared to
be lacking in its instructions to personnel. During this
inspection a planned revision, Revision 5, to 1.8 was
issued which was more comprehensive in its detail.
Although basically acceptable, the inspector observed
weaknesses in the program which could cause surveillance
tests to be occasionally not performed. The mechanism for
scheduling and tracking completed tests appeared to be
cumbersome, inefficient and open to potential errors.
The inspector made the following observations to the
licensee:
--
There is no centralized control of surveillance
testing. Although there is a master schedule, each
group controls its own surveillance tests. However,
no group in the plant lias its own procedures for
controlling its own test program.
--
Although a computer controlled schedule is issued, its
implementation is performed manually. Verification of
completed tests is by initials on a copy of the
computer schedule and depends on personnel from each
section going to the Control Room Annex and initialing
their completion. Initials are transposed as much as
3 or 4 times. After the third transposition, entries
are made to the computer. This system is prone to !
, transposition errors. l
l
. _ _ _ _ _ _ _ _ _ _ , , _ _
. .
6
--
The planning and scheduling group is informed of
changes to the schedule by the groups which perform
the test. If a change is not entered in the computer
it could be overlooked. There is no positive feedback
to the group making the change that schedule changes
have been actually made.
--
Postponed tests or tests not applicable to the current
mode are left on the weekly schedule for long periods
of time. This leads to clutter on the schedule and
potential errors with verification of completed tests.
--
Each group maintains its own completed procedures.
There is no routine independent review (outside tne
implementing group and other than sampling by QA) that
tests have actually been completed. Test planners do
not see completed tests but only initials on a
schedule.
The licensee acknowledged the inspectors comments and
stated that they recognized problems with the current
method of scheduling. They also indicated that action was
being taken to improve the current methods of scheduling
and controlling surveillance tests.
3.3.3 Except for the Master Surveillance Test Schedule procedure,
there appeared to be no administrative procedures for
control of test programs. While licensee representatives
were able to discuss mechanisms by which they control their
surveillance test programs no administrative procedures
were in place. In accordance with Station Procedure 1.8,
each station group has the responsibility for performing
their own surveillances. The lack of test programs was
also observed in the areas of I&C calibration and post-
modification testing.
ANSI Standard 18.7-1976, Paragraph 5.2.19, requires the
establishment of program procedures for the conduct and
control of surveillance test programs, post-maintenance
testing, and post modification testing. In addition, the
BECO QAM, Section 11, requires that all tests be performed
by qualified personnel; that approved test procedures be
established; that test procedures identify all prerequi-
sites and environmental conditions; that the Watch Engineer
or his designee evaluate and approve post modification and
post maintenance test results; and that the N0D Manager is
responsible for the evaluation and approval of periodic
surveillance test results. Although there is an adminis-
trative control procedure for the scheduling of periodic
. .
.
7
surveillance tests and for the preparation of periodic
surveillance tests, other programmatic aspects were not
included in procedures. Some examples of items should have
been included but were not included:
--
Mechanisms for overall control and performance of
tests.
--
Definition of personnel qualified to perform tests.
--
Methods by which prerequisites and environmental
conditions are to be determined.
--
Specifications of personnel who are designated to
approve and evaluate test results.
--
Definitions of the kinds of instruments to be included
in the instrument and control surveillance test
program.
--
Methods by which acceptance criteria are properly
specified.
--
Journal for post maintenance and post modification
test procedures.
Failure to establish an overall test program Administrative
Control procedure is contrary to 10 CFR 50, Appendix B,
Criterion XI; ANSI N18.7-1976, paragraph 5.2.19; and BECO
QAM Section 11 and is considered a violation (50-293/
87-04-04).
4. Instrument Calibration
4.1 Scope and Criteria
Refer to paragraph 3.1.
4.2 Program Review / Implementation
The inspector held discussions with Maintenance Group personnel to
evaluate those controls in place used to identify, schedule, track,
perform, and document calibration activities required by Technical
Specifications (T.S.). Also reviewed were those controls in place
that are used during the calibration of selected instrumentation that
support the performance of T.S. related surveillances.
The majority of instrument calibrations are performed by the Instru-
ment and Controls (I&C) section. The overall performance of the site
- - , . _ - . .. - _ .
. _. . . .- -. ..
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. .
8
calibration program is controlled via the Master Surveillance Track-
ing Program, thus calibration activities are designated as station
surveillance requirements. Scheduling of calibration activities is
controlled and documented through either weekly, monthly or semi-
annual surveillance test schedules. Each station group and their
respective sub groups are responsible for the performance of
scheduled calibrations. This includes the development and updating
of the data base, the performance, documentation and subsequent
revisions of completed calibrations.
Further discussions with Compliance and Administrative Group, Project
Control Group, and Maintenance sub group personnel included a review
of the following:
Weekly and monthly surveillance test schedules
Semi-annual Master Surveillance Tracking Program Test List
Variance Reports / Priority Notice Reports, and
Various surveillance procedures used during the performance of
calibrations
The inspector verified that calibration methods and associated
l frequencies had been established for installed instrumentation used
, during the performance of Technical Specification required
surveillances. As with Technical Specification required calibra-
! tions, these installed instrument calibrations are tracked, scheduled
and performed under the Master Surveillance Tracking Program. The
inspector selected four surveillance requirements associated with the
'
1) Standby Liquid Control Syst.em; 2) Standby Gas Treatment System and
the 3) Fire Protection System. This selection was made in order to
provide assurance that 1) installed instrumentation required to
support the completion of T.S. surveillances were included in the
Master Surveillance Test Schedule, 2) required frequencies had been
established, and 3) calibrations were being performed. From the
above selected surveillance requirements, the licensee was requested
to provide the appropriate surveillance procedure number which
documented the calibration of associated instrumentation used during
the performance of these surveillances. Subsequently, the inspector
reviewed the appropriate surveillance procedures which documented the
performance of these calibrations.
The inspector also observed a performance of surveillance procedure
8.M.2.-l.1 " Primary Containment Isolation System - Reactor High
Pressure" calibration and 8.M.2-2.10.2-16, " Low Pressure Coolant
Injection Break Detection Logic Functional Test - Division A". NRC
observation of these surveillances was conducted to verify that the
following was accomplished.
.
.
.
-
. .
9
Applicable surveillance procedures were approved, up-to-date,
and used throughout the conduct of the surveillance.
Appropriate personnel were notified prior to the start of the
test.
Calibrated test equipment was used.
Acceptance criteria were met, and if not, appropriate corrective
action was taken.
Properly specified parts and materials were identified, and
Following completion of the test, systems were aligned for
normal operation.
During the calibration of Reactor High Pressure sensor PS-261-23A,
"As-Found" values were found to be out-of-tolerance. The Barksdale
Switch adjustment cover and eventually the switch cover itself, had
to be removed in order for the I&C technicians to make the necessary
adjustment to bring the pressure sensor within the allowable
operating range. Subsequent inspection of the environmentally
qualified Barksdale switch cover plate gasket indicated the need for
replacement. However, the I&C technicians were unable to obtain a
new gasket because none were found in stock at the site. To provide
assurance that the gasket is replaced a work order was generated
against the pressure switch and the surveillance is not be considered
complete until the new gasket is replaced.
4.3 Findings
The inspector expressed some concern over the lack of programmatic
controls for controlling calibration activities. This also applies
to the calibration of installed instrumentation used to support
Technical Specification surveillances. Only through discussions with
various site personnel, was the inspector able to ascertain how the
calibration program was controlled and conducted. This is an example
of lack of programmatic controls contributing to the violation
identified in paragraph 3.3.3. above.
5. Measurement and Test Equipment (M&TE)
5.1 Scope and Criteria
Refer to paragraphs 3.1.
5.2 Program Review / Implementation
The inspector held discussions with individuals designated to ad-
. .
10
minister and control the site's measuring and test equipment. Con-
trol of this program is designated in Procedure 1.3.36, " Measurement
and Test Equipment". A review of this procedure governing the con-
trol of M&TE was conducted and verified to ensure that the program
was being implemented as intended. This verification included a
review of the following.
Calibration records
Toolroom controls
Equipment master list for I&C and Station Services
M&TE records
Staffing
A tour of the tool rooms controlled by the I&C group and the Station
Services Group and discussions with tool room attendants and their
supervisors was conducted to verify that the storage and issuance of
M&TE were being adequately controlled.
5.3 Findings
5.3.1 Issuance and retrieval of all M&TE is handled by the
toolroom attendants. M&TE was adequately controlled
through the utilization of calibration logs, history
records and issuance logs. Equipment was found to be
appropriately stored and identified. M&TE was found to
fall into one of the following categories:
Out for re-calibration
Segregated (due for re-calibration or inoperable)
In-use, and
j Restricted use
5.3.2 During the inspectors review of past calibration records,
it was determined that historical use evaluations for M&TE
found to be out-of-calibration was not being performed as
required by ANSI 18.7, and the PNPS M&TE Procedure 1.3.36.
Over 18 instances were found where these evaluations were
not completed by I&C and Station Services. Much of the
i problem with the Station Services group is attributable to
their not following through with the evaluation by not
contacting various groups to which were 'ssued evaluations
for corrective action. This lack of followup and interface
-. -- . -- -
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. .
11
resulted in the failure of the other groups to complete the
necessary actions. I&C attributed their failure to com-
plete these evaluations to staffing problems.
Failure to evaluate and document the effect of out-of-
calibration test equipment on previously performed tests is
contrary to ANSI N 18.7-1976, paragraph 5.2.16 and is
considered a violation (50-293/87-04-02).
No other violations or deficiencies were observed.
6.0 Refuel Bridge Modification and Preoperational Testing
6.1 Background and Purpose of the Inspection
The refueling bridge at Pilgrim Station is a rolling hoist primarily
to load new fuel into the reactor and remove the old fuel during
refueling outages.
The previous refueling bridge had a long history of both mechanical
and electrical equipment failure. The bridge failures during
previous refueling operations had caused considerable lost outage
time while repairs were being made. In addition, the frame of the
refueling bridge had been deformed and the controls were outdated.
Because of these problems, the licensee decided to replace the
existing refueling bridge with a new BWR 6 refueling bridge. Some
features of this new bridge include upgraded controls and drive
mechanism, improved high capacity air supply and semiautomatic
control. .
The purpose of this inspection was to verify that adequate preopera-
, tional testing of the new refueling bridge would be conducted prior
to the operational use of the bridge. In addition, the inspector
reviewed the areas of post mcdification training and surveillance
testing to determine that the licensee had adequately addressed these
areas in regard to the refueling bridge modification.
6.2 Criteria and Documents Reviewed
See paragraph 3.2 and Attachments B and C.
6.3 Scope
The inspector reviewed preoperational test procedures TP86-127 and
TP86-182 for the refueling bridge. These procedures were reviewed in
preparation for test witnessing, for technical and administrative
adequacy and to independently verify that testing satisfied
regulatory guidance and licensee commitments. They were also
reviewed to verify licensee review and approval, proper format, test
. .
12
objectives, prerequisites, initial conditions, test data recording
requirements and system return to normal. In addition, completed
portions of TP86-127 were reviewed. No refueling bridge testing was
conducted during this inspection.
6.4 Findings
During the above review, the inspector verified that the refueling
bridge interlocks described in the vendor's Instruction Manual
IM-01620, appeared to be adequately tested in the preoperational test
procedures. However, during the review of TP86-127, Section 11,
" Traveling Safety Control Interlock", the inspector noted discrepan-
cies in the refueling bridge positions for testing conducted in Zone
II (canal joining spent fuel pool to reactor cavity area) and Zone
III (spent fuel pool). These interlocks are provided to eliminate
the possibility of the fuel grapple running into the wall.
Specifically, after review of TP86-127, Attachment D, figure 1, which
shows the 3 zones in which the main hoist can travel, it appeared to
the inspector that bridge position numbers identified in Section II,
Zone II.b and Zone III.c. were incorrect.
The inspector discussed this concern with the licensee test director
who had performed this portion of the procedure on October 8,1986.
The test director stated that the refueling bridge position numbers
listed in the procedure were incorrect and that at the time he
conducted the test he had intended to correct the procedure.
Instead, he performed this section of the test using the correct
bridge position numbers and signed off the steps in the procedure as
complete, but failed to change the bridge position numbers in the
procedure and ensure that this was properly approved. This
constitutes a violation of Technical Specification 6.8.A for failure
to properly implement and maintain the procedure (50-293/87-04-03).
In addition to the concerns addressed above, the inspector discussed
the control of the conduct of the preoperational tests following
modifications with various licensee representatives. The inspector
found that no specific programmatic procedure which list the require-
ments for such items as testing holds and failure to meet acceptance
criteria during conduct of the test existed. The absence of a
procedure to control the conduct of preoperational testing is another
example of the violation discussed in paragraph 3.3.3 above.
7.0 Refueling Bridge Post Modification Training
The inspector discussed the training of licensee personnel concerning the
refueling bridge modification with two licensee training representatives.
They explained that training includes the following:
.
- . , - - . , , - - - . . - - -
w- - - - - ,e. . . - -
-
-,
..
. .o
-.
13
--
An on watch discussion with each licensed and unlicensed operator on
the applicability and requirements of the documents listed in
Attachment D, and
--
Hands-on training in the operation of the new refueling bridge for
all licensed and unlicensed operators.
The licensee representatives explained that the on-watch discussions have
already been conducted and the hands-on training will occur after the
refueling bridge preoperational testing has been completed and the system
turned over to operations. In addition, they noted that after the review
of the procedures listed in Attachment D, all changes to the procedures as
a result of the refueling bridge modification have been discussed with the
operators.
No deficiencies were identified with regard to the' licensee's program for
refueling bridge post modification training.
8.0 Surveillance Testing for Refueling Operations
8.1 Scope and Criteria
The inspector reviewed Procedure 4.3, " Fuel Handling", in order to
verify that the licensee had identified the surveillance testing
needed to be conducted prior to and during fuel loading / unloading.
The inspector noted that Procedure 4.3 included attachments which
identified the requirements for either specific systems to be
operable or specific surveillance test procedures to be performed.
The inspector compared these attachments with the Technical Speci-
fication requirements for fuel loading / unloading. See Paragraph 3.1
and Attachment B for requirements and inspection criteria.
8.2 Findings
The inspector noted that the Control Room high efficiency air
filtration system required to be operable per T.S. 3.7.B.2 was not
addressed in Procedure 4.3. The inspector questioned a licensee
representative concerning this item. He stated that this item had
been previously identified and was to be included in the next
revision of the procedure. The inspector reviewed a draft copy of
the procedure revision and verified that the requirement for system
operability was included. In addition, during review of Procedure
4.3, the inspector noted that step 18, of Attachment OPER-10
identified surveillance testing to be conducted per T.S. Table 3.1.1.
note 7. Step 18 specifically references three surveillance tests to
be conducted. However, the surveillances for reactor mode switch in
shutdown, manual scram and scram discharge volume high level are not
referenced in this step. After discussion with the licensee
representative, he committed to including a reference to these
,
_ - . . _ , , , - , - - - - - . _ - _ _ . - - - , - - . _ _ _ _ . - . -
- _ . -
- - - _ - - - - , . . . - - - . . . - ,
-.
. .
14
surveillances in step 18 of OPER-10. No violations or other
deficiencies were identified.
9.0 Quality Assurance / Quality Control (QA/QC) Interface
The Quality Assurance group is represented on-site, along with Quality
Control personnel. Thus, these independent groups are able to actively
monitor on going station activities. Discussions were held with the
Senior QA Engineer to ascertain QA's involvement with the site's
calibration and surveillance program. It was noted that a QA surveillance
program is in place to provide QA coverage of various site activities,
including the performance of calibrations and surveillances. A review of
completed QA surveillances within the area of calibration and surveil-
lances, performed during the past 12 months indicates that QA's
participation is adequate, for present staffing levels.
Approximately 17 QA surveillance reports were reviewed by the inspectors.
This review included the following:
Surveillance checklists
Evaluation sheets
Nonconformance reports, if applicable
Trending input sheets, and
Department responses, if applicable.
It was noted that QA personnel were identifying problems in areas such as
procedure adherence, inadequate procedure content, and usage of out-of-
calibration equipment. Station response and subsequent corrective action
to the items reviewed appeared to be timely as noted during the
inspector's review of the QA's weekly deficiency status report.
10.0 Management Meetings
Licensee management was informed of the scope and purpose of the
inspection at an entrance interview conducted on January 12, 1987. The
findings of the inspection were periodically discussed with licensee
representatives during the course of the inspection. An exit interview
was conducted on January 16,1987 (see Attachment A attendees) at which
time the findings of the inspection were presented.
At no time during this inspection was written material concerning
inspection findings provided to the licensee by the inspectors.
A subsequent telephone discussion concerning clarification of the
inspection findings was conducted between the inspector and Mr. E. Graham
on January 21, 1987.
. .
i
ATTACHMENT A
PERSONS CONTACTED
1. Licensee
- M. Akhtar Group Leader - Modifications Management
- M. Brosee Maintenance Section Manager
F. Famulari Quality Control (QC) Group Leader
D. Gerlits Senior Nuclear Training Specialist
F. Giardiello Compliance Engineer
- E. Graham Compliance Group Leader
- R. Grazio Field Engineering Section Manager
P. Hamilton Compliance Engineer
- S. Hudson Operations Section Manager
G. LaFond I&C Engineer
E. Larson Senior QA Engineer
- P. Mastrangelo Chief Operations Engineer
- L. Mcdonald Nuclear Management Service Department
Group Leader
M. McGuire Electrical Engineer
P. Moraites Assistant Chief Maintenance Engineer
S. Musial Tool Management Supervisor
A. Pederson Station Manager
K. Roberts Director of Outage Management
C. Santora Planning Analyst
R. Schifone Compliance Engineer
J. Serry
R. Sherry Chief Maintenance Engineer
D. Sukanek Station Services Group Leader
J. Thompson Training Requalification Instructor
J. Vender Mechanical Engineer
D. Witecki I&C Senior Engineer (Quadrex)
S. Wollman Principal Operations Engineer
- E. Ziemanski Nuclear Management Services Section Manager
The inspector also interviewed other licensee personnel including I&C
Technicians.
2. USNRC
M. McBride Senior Resident Inspector
- J. Lyash Resident Inspector
- Denotes those present at exit interview.
d'
'
t+
ATTACHMENT B
' PROCEDURES REVIEWED FOR CONTROL OF
SURVEILLANCE TESTING AND CALIBRATION
--
1.3.4 Procedures
--
1.3.6 Adherence to Technical Specifications -- 1.3.36 Measurement and Test Equipment
~ - -
1.8 Master Surveillance Tracking Program
--
'1.8.2 PM Tracking Program
--
2.1.5 Daily Surveillance Log (Technical Specifications and Regulatory
Agencies)
--
4.3 Fuel Handling
=
a
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L
ATTACHMENT C
REFERENCES REVIEWED FOR CONTROL OF
MODIFICATION AND TESTING OF THE
REFUELING BRIDGE
--
Pilgrim Nuclear dawer Station (PNPS), Technical Specifications
--
PNPS, Final Safety Analysis Report (FSAR)
--
Nuclear Operatio1s Procedure 83A6 (N0P83A6), Modification Management,
July 31, 1984.
--
Nuclear Operations Procedure 83E1 (N0P93EI), Control of Modifications to
Pilgrim Station, September 17, 1986.
--
Nuclear Operations Department, PNPS, Procedure No. TP86-127, Preoperation-
al Test for Refueling Bridge, Revision 6, January 7, 1987.
--
Nuclear Operations Department, PNPS, Procedure No. TP86-182, Preoperation-
al Test for Refueling Bridge / Vessel Disassembled, Revision 0, January 3,
1987.
--
Instruction Manual IM-01620, Refueling Platform BECO, Pilgrim Station,
P.O. No. 68521, Volume 1 of 2, Revision 0, February 25, 1986.
--
Safety Evaluation, PNPS, No. 2044, Approved January 6, 1987.
--
Modification Management Work Instruction Manual, Approved January 12,
1987.
1
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ATTACHMENT D
PROCEDURES AND DOCUMENTS INCLUDED
IN REFUELING BRIDGE POST MODIFICATION TRAINING
---
Technical Specifications 3.10 " Core Alterations", and bases.
--
Technical Specifications 3.3 " Reactivity Control", and bases.
--
PNPS Procedure 4.0 "SNM Inventory and Transfer Control".
--
PNPS Procedure 4.3 " Fuel Handling".
--
PNPS Procedure 5.4.2 " Refueling Floor High Radiation".
--
PNPS Procedure 2.2.75 " Fuel Handling and Servicing
Equipment".
--
PNPS Procedure 4.5 " Reactor Core Fuel Verification".
--
PNPS Procedure 8.10.1 " Refueling Interlocks Functional
through 8.10.6 Tests".